MEMORANDUM

To: Jodi Howard , U.S. EPA, Office of Air Quality Planning and Standards

From: Colin Hayes , Roy Oommen

, and Philip Crawford

, Eastern Research Group, Inc.

Date: August 2 5 , 20 10

Subject: Summary of August 24 , 20 10 Meeting Between EPA and t he Vinyl Institute (VI) to Discuss Items Proposed in VI Letter Dated August 16 th , 2010

On August 24 , 20 10 , members of Vinyl Institute (VI) and representatives of PVC manufacturing companies met with EPA at Research Triangle Park (RTP) . The attendees

and affiliation are listed below:

Name Representing Barry Christenso n Occidental Chemical Corporation

Ken ny Akins Georgia Gulf Corporation

Mary Bachynsky Formosa Plastics Corporation

Kevin Bloomer Westlake Chemical Corporation

M a rk G arza Shintech Incor porated

Otis Sistrunk PolyOne Corporation

John Westendorf Occidental Chemical Corporation

David Wise Shintech Incorporated

Greg Bocchi Vinyl Institute

Nate Johnson Georgia Gulf Corporation

Allen Bodron Westlake Chemical Corporation

Richard Krock Vinyl Institute

Bob Elam Dow Chemical

Peter de la Cruz Keller and Heckman (Attorney representing VI )

Gary McAlister U.S. EPA OAQPS

Mark Kataoka U.S. EPA OGC

Jodi Howard U.S. EPA OAQPS

Ken Hustvedt U.S. EPA OAQPSPeter Westlin U.S. EPA OAQPS

Robin Segall U.S. EPA OAQPS

Jennifer Gibbs U.S. EPA Region 6

Nick Parsons U.S. EPA OAQPS

Philip Crawford Eastern Research Group , Inc.

Roy Oommen Eastern Research Group, Inc.

Colin Hayes Eastern Research Group , Inc.

The meeting began at 2 :00 PM (ES T )

. A s ummary of the meeting’s discussion follows.

Industry Submitted Data Inconsistencies

 The VI began the meeting with an introduction stating the intent of VI was to cooperate in the MACT rule making and provide additional information to EPA. VI

indicated th at they are not officially representing Dow Chemical and Certain Teed, but have included Georgia Gulf Corporation.

Resin Sampling Data and Methods

 VI first addressed inconsistencies in resin sampling data. Before publication of the EPA PVC 114 Survey Data base, VI requested Keller and Heckman (KH) to create a database using the industry data submitted to EPA. KH noted several inconsistencies:

Resin sampling data was submitted to EPA by facilities in pounds (lbs) per lbs of dry resin production (lbs/lbs of d ry resin). Some companies calculated lbs of dry resin for their entire facility, while others only calculated resin production for the line from which the resin sample was obtained.

During resin analysis, a number of labs used a procedure which corrects f or water content in the resin sample. When facilities received the corrected results, unnecessary and incorrect moisture correction was again applied to the

results. VI stated that the confusion was the result of inconsistent test methods specified by EPA.

Facilities were inconsistent in the way percent solids were reported.

 In an effort to standardize the data set, VI has created a Microsoft (MS) Excel workbook containing industry data in a consistent format. VI presented the data set

for suspension and dispersion resin data. VI further categorized the data by assigning resin grade indications to the data points, based on resin inherent viscosity. The data

set also includes detection indicators (PQL, MDL, DL, ND) . VI stated that work was still being done to verify all of the indicators. EPA inquired when the data set would be finished. VI responded two to four weeks. EPA requested to receive the data set in stages and VI agreed. VI also indicated that the database does not contain Dow or Certain Teed data; however, if received, the VI would include the missing data. EPA inquired what percentage of the data included in VI’s MS Excel workbook was

currently denoted as ND. VI ran a filter of the data and indicated approximately 20%

of the data was above detect ion limit.

 VI discussed the inconsistent vinyl chloride monomer (VCM) test results obtained using Method 8260 and Method 107. Method 107 yields higher VCM extraction while 8260 extracts significantly less VCM from the sample matrix. VI is currently

attemp ting to produce a method with improved recovery and determine a factor to correct the results of 8260. VI has hired Environmental Chemistry of Houston Texas to assist in researching the methods. EPA Region Six confirmed that Method 107 yield ed a higher ext raction of VCM during the resin sampling

.

 EPA and VI briefly discussed how facilities normally test for residual VCM in the resin slurry and how facilities/labs performed testing for the ICR requirement. VI indicated that results for the ICR testing may h ave differed due to the increased sample settling time as a result of shipping the sample offsite.

 VI stated that when slurry is sampled, the matrix is initially well mixed, but after a short period of time the resin particles settle to the bottom of the matrix. VI stated that negligible amounts of VCM are contained in the water portion; therefore labs will “pour

- off” the water portion and deposit the remaining “wet cake” onto an absorbing substrate (e.g., paper towel). The wet cake is then analyzed and th e results are corrected for the water portion remaining in the wet cake.

Emissions Testing Data

 VI raised inconsistencies surrounding emissions testing of thermal oxidizer and vent gas adsorption (VGA) units. VI inquired how EPA intended to address the d ata inconsistency in setting the MACT floor. EPA responded that the Agency is still investigating the data. VI specifically mentioned PolyOne and the VGA technology used at the Pedricktown and Henry facilities. A PolyOne representative stated that the

VGA is online approximately 95% of the time and a thermal oxidizer is used when

the VGA is offline as the result of a malfunction or scheduled maintenance.

General

 VI presented a graph on analytes reported by industry. VI discussed how variability and potenti al “outlier” data may result from differing detection limits.

Non

- Detect Data Submitted by Industry

 VI asked how EPA intends to handle non

- detect (ND) data in the MACT floor analysis. EPA discussed how labs use different methods to determine detection l imits. EPA stated that the Agency has requested labs to report those detection limits in place of ND values. EPA proceeded to explain how recent proposed rulemakings have used ND values to account for variability in setting emissions limits.

Process and C hemistry Variability VI emphasized process variability due to chemistry variations between manufactures

and within facilities to meet a wide variety of customer specifications. VI stated that although facilities submitted 30 days of resin sampling data, a certain grade of resin may have only been made once during the thirty day period. VI believes that addressing chemistry variability will be a significant challenge for EPA and proposed to meet again with EPA in approximately three weeks to further discuss the issue. EPA requested an earlier meeting. VI indicated a webinar or teleconference is possible. EPA asked if variability was more significant in the slurry or in incinerator emissions. VI responded that slurry exhibits increased variability over inciner ator emissions. VI asked how EPA intended to handle variability but EPA indicated they

were undecided.

Discussion of N on

- representative Data Set

 VI discussed the overall data set submitted to EPA and uncharacteristic manufacturing period during which the data were obtained. VI commented that resin sampling and emissions testing data was obtained during winter months when PVC production is seasonally low. VI also mentioned in addition, current and recent economic conditions have also decreased PVC producti on. VI inquired how EPA plans to account for increased future production in the proposed rulemaking. VI suggests submitted previous years of Method 107 data. EPA asked when additional data would be available. VI responded that they were waiting on the Meth od 8260 / Method 107 research to be completed. EPA stated VI may submit additional data after the proposal. VI and EPA discussed if language related to “alternate test method approval by the administrator” will be included in the preamble.

Items Related t o Proposed Rulemaking

 EPA discussed the option of regulating emission points downstream of the stripper instead of requiring compliance by VCM content in the stripped resin slurry. VI responded that those particular emission points are difficult to contro l due to the high moisture content, high volume, and low volatile organic compound concentration of the streams. EPA requested more information from VI and industry regarding these emission points, specifically the technical reasons why control in not feas ible.

 VI asked EPA if the Agency intended to regulate Hazardous Air Pollutants (HAPs) as a whole or by individual compounds. EPA responded they were undecided.

 EPA inquired about PVC facilities co

- located with VCM facilities and why those

PVC facilities decided to comply with subpart UU ( 40 CFR Part 63 Subpart UU

– National Emission Standards for Equipment Leaks Control Level 2 Standards). VI responded that certain facilities comply with UU as part of a consent decree. In other cases facilities are compl ying with subpart UU as a PVC de facto MACT. VI also indicated that facilities try to limit the number of Leak Detection and Repair (LDAR) programs they must implement. For example, Louisiana facilities will comply with the most stringent LDAR program for co

- located facilities as part of an option offered by EPA Region Six.

Remaining Data Gaps VI inquired if any other specific data gaps existed and for which of those gaps VI

should focus effort on filling. ERG indicated that the wastewater and miscellan eous emissions sections of the surveys. ERG will provide a more detail list of missing

information to EPA in the near future.

 VI offered to present and additional PVC seminar “PVC 101” to EPA at a later date.

The meeting adjourned at approximately 3:30 PM.